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Home My WebLink AboutNC0077135_Compliance Evaluation Inspection_20191030ROY COOPER Governor MICHAEL S. REGAN Secretary LINDA CULPEPPER Director NORTH CAROLINA Environmental Quality Certified Mail # 70171450 0001 6450 4854 Return Receipt Requested October 30, 2019 Fred D. Curl Curl Modular Homes 707 N. English St Greensboro, NC 27405 Subject: Notice of Violation and Intent to Issue Civil Penalty NOV Tracking No. NOV-2019-PC-0724 NPDES Permit NCO077135 Hidden Valley WWTP, Rockingham County Dear Mr. Curl: On September 30, 2019, Paul DiMatteo of the Division of Water Resources (Division), Winston- Salem Regional Office met with Paul Smith, Operator in Responsible Charge (ORC), to conduct a Compliance Evaluation Inspection of the above referenced wastewater treatment plant. This inspection consists of (1) a review of the permit and accompanying documentation to determine compliance with permit conditions, and (2) an on -site inspection of several collection system components. The attached inspection form notes the areas that were evaluated for the inspection, with any notable findings outlined as follows: Summary of Non -Compliance The UV system was inoperable during the inspection. Please note that Part II, Section C.2 of the Permit requires that the Permittee, at all times, "properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the Permittee to achieve compliance with the conditions of this permit." Requested Response This Notice of Violation / Notice of Intent to Enforce (NOV/NOI) is being issued for the noted violation. Pursuant to G.S. 143 215.6A, a civil penalty of not more than twenty-five thousand dollars ($25,000.00) may be assessed against any person who violates or fails to act in accordance with the terms, conditions, or requirements of any permit issued pursuant to G.S. 143 215.1. This office requests that you respond to this Notice, in writing, within 10 business days of its receipt. In your response, you should address the causes of non-compliance, remedial actions, and all other actions taken to prevent the recurrence of similar situations. The response to this correspondence will be considered in this process. Enforcement decisions will also be based on D North Carolina Department of Environmental Quality I Division of Water Resources EQ�p Winston-Salem Regional Office 1 450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105 NORTH CAROLINA � o•o•°"•mme""°"^•"vin"•i� /� 336.776.9800 volume spilled, volume reaching surface waters, duration and gravity, impacts to public health, fish kills or recreational area closures. Other factors considered in determining the amount of the civil penalty are the violator's history of non-compliance, the cost of rectifying the damage, whether the spill was intentional and whether money was saved by non-compliance. If you have any questions concerning this report, please contact Paul DiMatteo at (336) 776-9691 or Lon Snider at (336) 776-9800. Sincerely, DocuSiiggned by: 1 _"49E225C94EA... Lon T. Snider, Regional Supervisor Water Quality Regional Operations Section Winston-Salem Regional Office Division of Water Resources, NCDEQ Enclosures — Inspection Report CC: WSRO Laserfiche Files United States Environmental Protection Agency Form Approved. EPA Washington, D.C. 20460 OMB No. 2040-0057 Water Compliance Inspection Report Approval expires 8-31-98 Section A: National Data System Coding (i.e., PCS) Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type 1 IN I 2 IF I 3 I NCO077135 111 12 I 19/09/30 I17 18 I S J 19 L G] 201 I 211111 I I I I I I II I I I I I I I I I I I I I I I I I I I I I I I II I I I I I f6 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved ------------------- 671 70 I I 71 I I 72 I r I 73 I I 174 751 I I I I I I I80 u I� I I i Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include Entry Time/Date Permit Effective Date POTW name and NPDES oermit Number) 12:45PM 19/09/30 17/06/01 Hidden Valley WWTP US Hwy 29 Business Exit Time/Date Permit Expiration Date Reidsville NC 27320 01:30PM 19/09/30 22/04/30 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Paul Matthew Smith/ORC/336-932-9347/ Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Fred D Curl,707 N English St Greensboro NC 27405/Owner/336-379-9155/3363799155 No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit 0 Flow Measurement Operations & Maintenance Records/Reports Self -Monitoring Program 0 Facility Site Review Effluent/Receiving Waters Laboratory Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) (See attachment summary) Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date Paul DiMatteo DocuSigned by: DWR/WSRO WQ/336-776-9691/ !� 4L 10/30/2019 F10C7C2E5131334D4... Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date DocuSigned by: �ti T Strider 10/30/2019 FL EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# NPDES yr/mo/day Inspection Type NCO077135 I11 121 19/09/30 117 18 JCJ Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Page# Permit: NCO077135 Owner - Facility: Hidden Valley WWTP Inspection Date: 09/30/2019 Inspection Type: Compliance Evaluation Operations & Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? 0 ❑ ❑ ❑ Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ❑ ❑ ❑ Solids, pH, DO, Sludge Judge, and other that are applicable? Comment: Permit Yes No NA NE (If the present permit expires in 6 months or less). Has the permittee submitted a new ❑ ❑ ❑ application? Is the facility as described in the permit? 0 ❑ ❑ ❑ # Are there any special conditions for the permit? ❑ 0 ❑ ❑ Is access to the plant site restricted to the general public? 0 ❑ ❑ ❑ Is the inspector granted access to all areas for inspection? 0 ❑ ❑ ❑ Comment: Record Keeping Yes No NA NE Are records kept and maintained as required by the permit? 0 ❑ ❑ ❑ Is all required information readily available, complete and current? 0 ❑ ❑ ❑ Are all records maintained for 3 years (lab. reg. required 5 years)? 0 ❑ ❑ ❑ Are analytical results consistent with data reported on DMRs? 0 ❑ ❑ ❑ Is the chain -of -custody complete? 0 ❑ ❑ ❑ Dates, times and location of sampling Name of individual performing the sampling Results of analysis and calibration Dates of analysis Name of person performing analyses Transported COCs Are DMRs complete: do they include all permit parameters? ❑ ❑ ❑ Has the facility submitted its annual compliance report to users and DWQ? ❑ ❑ ❑ (If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator ❑ ❑ ❑ on each shift? Is the ORC visitation log available and current? ❑ ❑ ❑ Is the ORC certified at grade equal to or higher than the facility classification? ❑ ❑ ❑ Is the backup operator certified at one grade less or greater than the facility classification? ❑ ❑ ❑ Is a copy of the current NPDES permit available on site? ❑ ❑ ❑ Page# 3 Permit: NCO077135 Owner - Facility: Hidden Valley WWTP Inspection Date: 09/30/2019 Inspection Type: Compliance Evaluation Record Keeping Yes No NA NE Facility has copy of previous year's Annual Report on file for review? ❑ ❑ 0 ❑ Comment: Effluent Pipe Yes No NA NE Is right of way to the outfall properly maintained? 0 ❑ ❑ ❑ Are the receiving water free of foam other than trace amounts and other debris? 0 ❑ ❑ ❑ If effluent (diffuser pipes are required) are they operating properly? ❑ ❑ 0 ❑ Comment: Flow Measurement - Effluent Yes No NA NE # Is flow meter used for reporting? M ❑ ❑ ❑ Is flow meter calibrated annually? ❑ ❑ 0 ❑ Is the flow meter operational? 0 ❑ ❑ ❑ (If units are separated) Does the chart recorder match the flow meter? ❑ ❑ 0 ❑ Comment: Monitoring requirement is weekly instantaneous. ORC said he measures it using a ruler at the V-Notch weir after the clarifier. Bar Screens Yes No NA NE Type of bar screen a.Manual b.Mechanical ❑ Are the bars adequately screening debris? ❑ ❑ ❑ Is the screen free of excessive debris? ❑ ❑ ❑ Is disposal of screening in compliance? ❑ ❑ 0 ❑ Is the unit in good condition? ❑ ❑ 0❑ Comment: ORC reported that the bar screen is not really in use. Mascerator pumps are used to decrease particle size, and degris is pumped as needed, but some buildup of grease and debris was observed. Equalization Basins Yes No NA NE Is the basin aerated? ❑ ❑ 0 ❑ Is the basin free of bypass lines or structures to the natural environment? 0 ❑ ❑ ❑ Is the basin free of excessive grease? 0 ❑ ❑ ❑ Are all pumps present? 0 ❑ ❑ ❑ Are all pumps operable? 0 ❑ ❑ ❑ Page# 4 Permit: NCO077135 Owner - Facility: Hidden Valley WWTP Inspection Date: 09/30/2019 Inspection Type: Compliance Evaluation Equalization Basins Yes No NA NE Are float controls operable? 0 ❑ ❑ ❑ Are audible and visual alarms operable? ❑ ❑ ❑ # Is basin size/volume adequate? 0 ❑ ❑ ❑ Comment: Aeration Basins Yes No NA NE Mode of operation Ext. Air Type of aeration system Diffused Is the basin free of dead spots? 0 ❑ ❑ ❑ Are surface aerators and mixers operational? ❑ ❑ 0 ❑ Are the diffusers operational? 0 ❑ ❑ ❑ Is the foam the proper color for the treatment process? 0 ❑ ❑ ❑ Does the foam cover less than 25% of the basin's surface? 0 ❑ ❑ ❑ Is the DO level acceptable? ❑ ❑ ❑ Is the DO level acceptable?(1.0 to 3.0 mg/1) ❑ ❑ ❑ Comment: Color appeared "thin", reportedly due to low flow compared to design flow. Secondary Clarifier Yes No NA NE Is the clarifier free of black and odorous wastewater? 0 ❑ ❑ ❑ Is the site free of excessive buildup of solids in center well of circular clarifier? 0 ❑ ❑ ❑ Are weirs level? ❑ 0 ❑ ❑ Is the site free of weir blockage? 0 ❑ ❑ ❑ Is the site free of evidence of short-circuiting? 0 ❑ ❑ ❑ Is scum removal adequate? 0 ❑ ❑ ❑ Is the site free of excessive floating sludge? 0 ❑ ❑ ❑ Is the drive unit operational? ❑ 0 ❑ ❑ Is the return rate acceptable (low turbulence)? ❑ ❑ ❑ Is the overflow clear of excessive solids/pin floc? E ❑ ❑ ❑ Is the sludge blanket level acceptable? (Approximately'/4 of the sidewall depth) ❑ ❑ ❑ Comment: Clarifier was covered in duck weed. Additionally, the drive unit does not work, and weirs did not appear to be completely level. Issues with the drive unit and weirs were noted during the previous inspection. However, the CIRC claimed that having these issues fixed was not a Priority to the owner due to prolonged low flows. Page# 5 Permit: NCO077135 Inspection Date: 09/30/2019 Owner - Facility: Hidden Valley WWTP Inspection Type: Compliance Evaluation Disinfection - UV Yes No NA NE Are extra UV bulbs available on site? ❑ 0 ❑ ❑ Are UV bulbs clean? ❑ ❑ ❑ Is UV intensity adequate? ❑ 0 ❑ ❑ Is transmittance at or above designed level? ❑ 0 ❑ ❑ Is there a backup system on site? 0 ❑ ❑ ❑ Is effluent clear and free of solids? 0 ❑ ❑ ❑ Comment: Intensity meter read 0 during the inspection. The ORC checked it and determined that it wasn't working properly. ORC also reported that he keeps extra bulbs at his house due to theft concerns, and if needed chlorine would be added to the clarifier train for disinfection. ORC said he would add chlorine after the inspections. Standby Power Is automatically activated standby power available? Is the generator tested by interrupting primary power source? Is the generator tested under load? Was generator tested & operational during the inspection? Do the generator(s) have adequate capacity to operate the entire wastewater site? Is there an emergency agreement with a fuel vendor for extended run on back-up power? Is the generator fuel level monitored? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ Comment: ORC said he does not test the backup power, but it is managed by the property owner. He said he thought it was operating properly and that they did do regular checks. Documentation of tests should be kept and available for review during inspections. Laboratory Are field parameters performed by certified personnel or laboratory? Are all other parameters(excluding field parameters) performed by a certified lab? # Is the facility using a contract lab? # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees? Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees? Comment: Effluent Sampling Is composite sampling flow proportional? Is sample collected below all treatment units? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ Yes No NA NE ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ Page# 6 Permit: NCO077135 Owner - Facility: Hidden Valley WWTP Inspection Date: 09/30/2019 Inspection Type: Compliance Evaluation Effluent Sampling Yes No NA NE Is proper volume collected? ❑ ❑ ❑ Is the tubing clean? ❑ ❑ 0 ❑ # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees ❑ ❑ ❑ Celsius)? Is the facility sampling performed as required by the permit (frequency, sampling type 0 ❑ ❑ ❑ representative)? Comment: Collected after UV. Upstream / Downstream Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type, and 0 ❑ ❑ ❑ sampling location)? Comment: Upstream samDle is collected aDDroximately 100 feet upstream of the outfall: downstream approximately 150 ft downstream. The permit lists the Downstream sampling location as at US 29 but the operator argued that conditions off US 29 were not conducive to sampling, and that a closer downstream location would more accurately capture any impacts caused by the plants. This should be clarified in the Permit. Page# 7